TN: Consent in the face of a threat to get a SW is invalid where no PC

Defendant’s consent in the face of the officer’s threat to get a search warrant was involuntary where there was no probable cause for a warrant. State v. Cohen, 2021 Tenn. Crim. App. LEXIS 356 (July 29, 2021).

There was reasonable suspicion for a border search of defendant’s cell phone when he arrived at O’Hare. CBP was on the lookout for defendant coming with potential possession of child pornography. United States v. Mendez, 2021 U.S. Dist. LEXIS 140738 (N.D.Ill. July 28, 2021).*

A police car parking near defendant’s car and turning on the takedown lights but not emergency lights isn’t a seizure. “Officer Nelson’s use of his police vehicle’s takedown lights to illuminate the parked car—as opposed to turning on flashing emergency lights—does not change that conclusion. Other circuits have agreed that shining a bright light into a vehicle is not inherently coercive.” United States v. Tafuna, 2021 U.S. App. LEXIS 22442 (10th Cir. July 27, 2021).